Safety, was invited to provide testimony on November 2, 2010, in Chicago, Illinois. A question the subcommittee explored on this particular day was the feasibility, steps, and timelines of planning and executing a large-scale SNF shipment in three to five years. Speaking from the state of Illinois’ experience with conducting safety inspections and providing security escorts for about 1,000 SNF shipments, Mr. Runyon did not think this would be feasible: There has not been a major rail campaign across the U.S. in nearly two decades and with the changes in security requirements in the post 9-11 world along with the routing, inspection and general transportation planning and coordination, we would estimate it could take 7 to 9 years to develop a viable nationwide transportation program that would have widespread public acceptance and confidence (Runyon 2010). Additionally, Lisa Janairo (CSG Midwest), lead staffer to the MRMTC, also testified at the Chicago meeting. In her testimony, Ms. Janairo made two key points to the subcommittee: 1. Transportation of radioactive materials is an activity in its own right with a technical side, an institutional side, and a political side. As such, transportation needs to be given the same attention and care as any other part of the nuclear fuel cycle; and 2. States absolutely must be involved in planning, preparing for, and executing radioactive materials shipments (Janairo 2010). Based on her experiences with several DOE shipping campaigns to move SNF, Ms. Janairo believed the subcommittee’s three- to five- year timeline was far too optimistic, especially given the prior pace of progress within DOE’s Civilian Radioactive Waste Management System. Taking into account route identification, financial and technical assistance, public information campaigns, security planning, staffing federal and state programs, and other activities, Ms. Janairo testified that it would take nine to 12 years to properly plan for a safe, secure, and efficient SNF shipping campaign that would merit public confidence (ibid.).
The subcommittee released its draft report to the full commission on May 31, 2011. The report centered around seven recommendations, paraphrased as follows: 1. The United States should proceed expeditiously to establish one or more consolidated interim storage facilities as part of an integrated, comprehensive plan for managing the back end of the nuclear fuel cycle. 2. To ensure that all near-term forms of storage meet high standards of safety and security for the multi-decade-long time periods that they are likely to be in use, active research should continue on issues such as degradation phenomena, vulnerability to sabotage and terrorism, full-scale cask testing, and other matters. 3. Spent fuel currently being stored at decommissioned reactor sites should be “first in line” for transfer to a consolidated interim storage facility as soon as such a facility is available. 4. A new organization charged with developing one or more permanent disposal facilities should also lead the development of consolidated storage and transportation capabilities. 5. Processes used to develop and implement all aspects of the spent fuel and waste management system should be science- based, consent-based, transparent, phased, and adaptive. They should also include a properly designed and substantial incentive program. 6. Planning and coordination for the transport of spent fuel and high-level waste is complex and should commence at the very start of a project to develop consolidated storage capacity. 7. The Subcommittee recommends that the Administration and Congress take action to provide full access to the Nuclear Waste Fund for the purposes for which it was intended, including funding consolidated interim storage and transportation as an integral part of broader waste management efforts (BRC 2011a, p. 64-69). After publishing this report, the BRC allowed some time for public comment. The MRMTC provided their comments on June 30, 2011. Many of these comments expressed appreciation that the subcommittee’s findings and recommendations reflected the region’s provided testimony — for example, the recommendation to fully involve state and other government officials in developing storage and transportation solutions. The MRMTC encouraged the subcommittee to look to current and past successful shipping campaigns for inspiration: It will also be important for DOE or a successor organization to commit to establishing and maintaining the type of productive working relationships that the states have had with programs such as DOE’s Carlsbad Field Office (CBFO) (for shipments to the Waste Isolation Pilot Plant, or WIPP) and, before it was eliminated, the former Office of Civilian Radioactive Waste Management (OCRWM)” (Schmidt and Runyon 2011a, p. 2). The comments also requested that the subcommittee address the limitations of Section 180(c) of the NWPA. For example, DOE interprets its obligation under Section 180(c) as strictly limited to training,
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